The IRDAI window shut. Now the count becomes a question

One closing in the consultation ledger this week: IRDAI's paper on recalibrating the economics of insurance distribution shut on 31 October, after the regulator's 24 October release reported more than 650 comments and extended the deadline from 25 October. The row still carries comments_published: unknown. Feedback flowed through an IIB-run portal, an Excel template and an email inbox — channels that produce a count, not a public record of who asked for what. IRDAI's own June draft framework for regulation-making, still unnotified (proposed in the ledger), would require a published statement of response by notification date. The test for this file is whether that standard arrives before the final rules do.

The count also has a named shape. ETBFSI reported banks and small finance banks routing objections through the Indian Banks' Association and the Association of Small Finance Banks, seeking transition time — one mid-sized private bank CEO said its representation went via IBA. IBA is a registered interest on LobbyWatch's interests page, and bancassurance fee income is exactly what the proposed caps on credit-linked insurance would cut.

Two SEBI windows close this week, both in the ledger with comment publication unverified: issue-proceeds monitoring on 3 November (paper) and SME IPO rules on 4 November (paper). The MII automatic-approval-route paper runs to 12 November.

The doors ledger records no appointment dated this week. Fresh reporting brushes against it: a 30 October Businessworld investigation maps 17 former public officials across Fairfax group companies — including two moves already in our ledger (B.P. Kanungo to IIFL Finance's chair; G. Mahalingam to LIC's board). The article itself states there is no allegation and no public evidence that any of them influenced the IDBI sale; we say the same. Its overlap of record — Mahalingam's 19 December 2025 Thomas Cook India seat, held while he sat on LIC's board and investment committee — is a candidate row, not a recorded one: LobbyWatch adds door moves only off primary sources, and the Thomas Cook and CSB Bank appointments await exactly that.

With the IRDAI window shut, the ready next step is ours: the comments-disclosure RTI template (TPL-01) against IRDAI's CPIO. The RTI log holds two template-ready entries and zero filings. Next watch: the two SEBI deadlines, and whether IRDAI's 650+ comments ever become visible.